BEPS 2.0 - Part 3: Pillar Two * If you would like to learn how Lexology can drive your content marketing strategy forward, please email [email protected] . Related research hubs

In November 2019, the OECD also released the Global Anti-base Erosion (GloBE ) proposal, the so-called Pillar 2 of the BEPS 2.0 project. On 12 October 2020,

additional taxing rights. where other jurisdictions BEPS 2.0: Latest updates on Pillar I and II. Jim Matthews Partner - Transfer Pricing and Value Chain Transformation, PwC Switzerland 02 Oct 2020. Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. Addressing the tax challenges raised by digitalisation has been a top priority of the OECD/G20 Inclusive Framework in BEPS since 2015 with the Be ready for BEPS 2.0. As the IF continues to work on achieving consensus on the Blueprints, MNEs will need to closely monitor developments, identify and determine whether the changes arising from BEPS 2.0 will have a significant financial impact on them (e.g., through financial modelling of how Pillar One and Pillar Two principles may affect BEPS 2.0 Developments: Pillar One The OECD’s request for public comments on the BEPS 2.0 proposals has met with great interest, with over 200 responses received.

Beps 2.0 pillar 2

In summary, Pillar One focuses on the allocation of taxing rights. Pillar Two focuses on the remaining BEPS issues and seeks to develop rules that introduce the concept of a global minimum rate of tax. Overview of the Pillar 1 Proposed Tax Dispute Resolution Process. Feb 2021. publication. Pillar 1 of BEPS 2.0 is made up of two parts.

Despite the United States’ reluctance to support Pillar 1 and the widely diverging views of different nations, there is still strong political pressure to progress. 2020-10-15 BEPS 2.0 (Pillar 2) - How will the anticipated overhaul of international tax rules impact on aircraft leasing?

BEPS 2.0: Update on Inclusive Framework’s Progress on Pillars One and Two. Pillars One and Pillar Two – High-level overview of the latest proposals;

December 2020 Following the release of our first newsletter on the topic, check out our latest thoughts on the possible impact of the BEPS 2.0 (pillar two) proposed rules on specific aircraft leasing platform jurisdictions and structures. Overview of the Pillar 1 Proposed Tax Dispute Resolution Process. Feb 2021. publication.

With respect to Pillar Two, the Report suggests that the global revenue gains from the proposal could be significant, representing the bulk of the potential gains from the BEPS 2.0 project. The Report notes that the impact of Pillar Two would fall on MNEs with low-taxed profits, including due to profit-shifting behavior.

The documents released by the IF on 12 October include the following. January 2020: The OECD released a statement on the two-pillar approach to address the tax challenges arising from the digitalisation of the economy, announcing that the Inclusive Framework members had renewed their commitment to the BEPS 2.0 project and providing a revised pillar one PoW and an update on pillar two, which was also endorsed by the G20. BEPS 2.0 - Part 3: Pillar Two * If you would like to learn how Lexology can drive your content marketing strategy forward, please email [email protected] . Related research hubs Unfortunately, the BEPS 2.0 proposals expose an inherent policy conflict between the original policy strands of BEPS 1.0, in that, it no longer seems possible for a source country to choose not to tax income sourced there - or, perhaps more correctly, if it does so choose, it may get taxed elsewhere – under the Pillar Two income inclusion rule. The fourth and final part of this series (albeit not the end of BEPS 2.0) considers the responses of different jurisdictions to the proposals under Pillar One and Pillar Two. EU response Summary: The Pillar One and Two blueprints (BEPS 2.0) following a meeting of the OECD-led coalition of 137 countries, were released yesterday. Contrary to expectations, there was no agreement on either blueprint by the Inclusive Framework members and it is now expected that consensus could be achieved by mid-2021. OECD-Vorschlag zu Pillar 2. Am 08.11.2019 veröffentlichte die OECD das Konsultationspapier zum „Global Anti-Base Erosion Proposal“ (GloBE) als zweite Säule („Pillar 2“) der BEPS 2.0-Initiative „Addressing the Tax Challenges of the Digitalisation of the Economy“.

granting jurisdictions . additional taxing rights. where other jurisdictions BEPS 2.0: Latest updates on Pillar I and II. Jim Matthews Partner - Transfer Pricing and Value Chain Transformation, PwC Switzerland 02 Oct 2020. Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers.
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Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers.

Further reading & resources. KPMG report Pillar Two KPMG report taxation of the digitalized economy KPMG in the UK digitalized economy portal page KPMG BEPS 2.0 Model . Leveling the playing field — Pillar Two has . four new rules.
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21 Oct 2020 The premise behind the Pillar Two proposal is simple, if a state does not exercise their taxing rights to an adequate extent, a new network of rules

1 The OECD Guidelines for Multinational Enterprises argue that corporations should the four pillars availability, access, utilization and stability.140 Production [RSB-STD-01-001 (version 2.0)”, Geneva: RSB. CRS och DAC 2. BEPS – ett arbete inom OECD. [2] Location of Kaliningrad.

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OECD:s “Pillar 1” och “Pillar 2” - nu är rapporterna publicerade. För att uppnå samstämmighet, substans och transparens på skatteområdet och

Overview of the Pillar 1 Proposed Tax Dispute Resolution Process. Feb 2021. publication. Pillar 1 of BEPS 2.0 is made up of two parts. One part, Amount A allocates a portion of deemed residual profits of certain in-scope multinational enterprises (MNE) to market jurisdictions. The Pillar One and Two blueprints (BEPS 2.0) following a meeting of the OECD-led coalition of 137 countries, were released yesterday.